News & Analysis as of

Military Lending Act Department of Defense (DOD)

Ballard Spahr LLP

Military Lending Act violations alleged against title lender in Georgia class action

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A proposed class action lawsuit filed in the U.S. District Court for the Northern District of Georgia on February 21, 2024 against TitleMax of Georgia, Inc. and TMX Finance LLC (together, “TitleMax”) accuses the Georgia-based...more

Hudson Cook, LLP

Fourth Circuit Takes Expansive View of MLA Auto-Loan Exemption

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In a decision highly anticipated by the auto finance industry, a federal appeals court recently held that auto loans remain exempt from the Military Lending Act even when they finance related costs or services beyond the...more

Troutman Pepper

Which MLA Safe Harbor Are You Using? Recent Decision Highlights Overlap and Distinction Points

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A recent federal court decision from the Northern District of Texas offers some useful lessons and insights for creditors relying on the Military Lending Act’s (MLA) safe harbors for verifying whether a consumer is a “covered...more

Hudson Cook, LLP

Federal Agencies Take Another Shot at GAP Coverage for Buyers Covered by the Military Lending Act

Hudson Cook, LLP on

I have always been a fan of suspenseful entertainment. I really like television shows where it looks like the protagonist is doomed, but then escapes, lands back in trouble, and gets out ... again! So fun. Originally...more

Ballard Spahr LLP

Dept. of Defense issues report to Congress on Military Lending Act rate cap

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The Department of Defense (DoD) has issued a report to the House Committee on Armed Services regarding the impact of a Military Annual Percentage Rate (MAPR) cap lower than 30% on military readiness and servicemember...more

Hudson Cook, LLP

CFPB Announces Broad Military Lending Act Compliance Sweep

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On December 4, 2020, the Consumer Financial Protection Bureau announced the filing of a lawsuit against an online lender for allegedly violating the Military Lending Act ("MLA"). The CFPB's complaint alleges that the lender...more

Bradley Arant Boult Cummings LLP

Department of Defense Withdraws Troublesome Military Lending Act Guidance

In a significant victory for servicemembers and their families, who will again have access to products designed to protect them in the event of a total vehicle loss, the Department of Defense has revised its guidance that...more

Ballard Spahr LLP

Department of Defense Reverts to Prior Position on MLA Interpretive Rule Q&A #2 Regarding Motor Vehicle and Personal Property...

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In a new interpretive rule published on February 28, 2020, the Department of Defense (DoD) has announced that it is withdrawing guidance previously issued in its December 14, 2017 Interpretive Rule, Q&A #2, governing motor...more

Ballard Spahr LLP

DoD to propose amendment to MLA regulations on auto financing

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The Department of Defense announced in its Fall 2019 rulemaking agenda that it is engaged in proposed rulemaking to amend its Military Lending Act (MLA) regulations, apparently in order to allow non-bank creditors to provide...more

Hudson Cook, LLP

Don't Forget About the Military Lending Act

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Until December 2017, the auto industry operated under the understanding that the federal Military Lending Act's (MLA) exclusion from coverage for credit transactions "expressly intended to finance the purchase of a motor...more

Ballard Spahr LLP

Industry continues efforts seeking withdrawal of Department of Defense MLA interpretation on GAP insurance financing

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Early last year, several trade groups, including the National Automotive Dealers Association (NADA), sent letters petitioning the Department of Defense (DoD) to rescind or withdraw Question and Answer #2 (Q&A 2) from its 2016...more

Ballard Spahr LLP

Trump Administration Plans to End Military Lending Act Prohibition on Offering GAP Insurance to Service Members in Auto Loan...

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NPR reported last week that the Trump Administration is planning to end the current prohibition under the Military Lending Act (“MLA”) against creditors offering service members GAP insurance in connection with credit...more

Ballard Spahr LLP

More industry groups petition Department of Defense to withdraw MLA interpretation on GAP insurance financing—is a response...

Ballard Spahr LLP on

We previously reported that several trade groups had sent letters petitioning the Department of Defense (DoD) to rescind or withdraw Question and Answer #2 (Q&A 2) from its 2016 interpretative rule for the Military Lending...more

Ballard Spahr LLP

Update to MLA Website Expands Search Functionality

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Yesterday, the Department of Defense’s (DoD) Military Lending Act website was temporarily taken offline to accommodate various “security and performance enhancements.” ...more

Ballard Spahr LLP

Trade groups ask Defense Dept. to rescind MLA interpretation on GAP insurance financing

Ballard Spahr LLP on

Four trade groups have sent letters to the Department of Defense (DoD) asking the DoD to rescind or withdraw Question and Answer #2 (Q&A 2) from its 2016 interpretative rule for the Military Lending Act final rule (MLA Rule)...more

Manatt, Phelps & Phillips, LLP

DoD Expands Guidance on MLA

The Department of Defense (DoD) released a new interpretive rule under the Military Lending Act (MLA), building on prior interpretive guidance. What happened - Enacted in 2006, the MLA caps the total charge on covered...more

Morrison & Foerster LLP

Department of Defense Publishes Amends and Adds Further Guidance on Military Lending Act Regulations

Morrison & Foerster LLP on

On December 14, 2017, the Department of Defense (“DOD”) published final interpretive rules (the “2017 Interpretive Rule”) amending previously issued interpretive rules on the Military Lending Act (“MLA”). The 2017...more

Ballard Spahr LLP

Department of Defense Issues Additional MLA Rule Interpretive Guidance; SCRA Foreclosure Protections Extended

Ballard Spahr LLP on

Last week the Department of Defense (DoD) issued an interpretive rule under the DoD’s Military Lending Act final rule (MLA Rule). The interpretive rule amends four of the “Q&A” format interpretations that DoD issued on August...more

Ballard Spahr LLP

MLA Compliance Deadline For Credit Card Accounts Is Tuesday, October 3

Ballard Spahr LLP on

The Military Lending Act (MLA) will apply to credit card accounts starting Tuesday, October 3. The final rule took effect last October but provided a one-year exemption for “credit extended in a credit card account under an...more

Ballard Spahr LLP

Defense Dept. rejects trade group’s request for extension of Oct. 3 MLA compliance date for credit cards

Ballard Spahr LLP on

The Department of Defense (DoD) is reported to have rejected the request of the National Association of Federally-Insured Credit Unions (NAFCU) to extend the October 3, 2017 date for credit card compliance with the Military...more

Ballard Spahr LLP

Propoposed Bill Would Significantly Expand MLA Disclosure Requirements

Ballard Spahr LLP on

We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to...more

Ballard Spahr LLP

CFPB’s Office of Servicemember Affairs Issues Annual Report

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The CFPB’s Office of Servicemember Affairs (OSA) has issued its fifth annual report to Congress addressing issues raised and complaints submitted by servicemembers, veterans, and their families....more

Ballard Spahr LLP

MLA Website malfunction

Ballard Spahr LLP on

According to an announcement posted on the Military Lending Act (“MLA”) Website, “[b]etween February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from...more

Burr & Forman

Military Lending Act Compliance

Burr & Forman on

On October 3, 2017, the Department of Defense’s revised Military Lending Act (“MLA”) regulations will apply to consumer credit card accounts. These regulations require significant changes and will alter the landscape of how...more

Ballard Spahr LLP

CFPB to participate in interagency MLA webinar

Ballard Spahr LLP on

On December 1, 2016, the  FDIC will co-host an interagency webinar that will focus on Military Lending Act regulations and the Department of Defense’s recently-released interpretive rule. In addition to a CFPB...more

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